Ethical Code

Ethical business conduct is critical to our business and a shared responsibility of all members of FOKABEKS. Each employee is responsible for protecting our most valuable asset – our reputation. This Code of Ethics (the “Code”) applies to anyone conducting business on behalf of FOKABEKS or any of its subsidiaries, including but not limited to all managers, officers, employees, agents, representatives, lobbyists, interns, contractors, suppliers, and consultants (“Covered Parties”), and seeks to guide our legal and ethical responsibilities, to deter wrongdoing, and to promote:

Compliance with applicable laws, rules and regulations;
Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relation-ships;
The integrity of our financial information, which influences the decisions of management , as well as the ways in which the outside world perceives and evaluates us;
Full, fair, accurate, timely and understandable disclosure in reports and documents we file with or submit to government authorities and in other public communications; and
Accountability for adherence to this Code, including prompt internal reporting of any suspected violations.
To meet these objectives, this Code encourages Covered Parties to express any concerns they may have relating to corporate accountability. No discrimination or retaliation against any person who, in good faith, reports such concerns will be tolerated. Anyone who retaliates against an indi-vidual under such circumstances will be subject to disciplinary action, up to and including termination of employment.

All Covered Parties must read, understand, and adhere to this Code and all other applicable FOKABEKS policies. Violations of law, this Code or other FOKABEKS policies or procedures can lead to disciplinary action, up to and including termination of employment and/or termination of business relations.

Article 1 – Premise

FOKABEKS structures its own internal and external activities according to the principles set forth in this Code, with the conviction that ethics in the conduct of business activities must be pursued at the same time and with equal emphasis as the economic success of the business. FOKABEKS is committed to conducting its business in accordance with the highest standards of ethical behaviour, complying with all applicable laws and regulations, avoiding even the appearance of unethical or illegal conduct.

Article 2 – Objectives and Values

The primary objective of the FOKABEKS is to create value for the shareholders. Industrial and financial strategies and the resulting operative conduct, based on the efficient use of resources, are oriented to achieving this goal. In pursuing this objective FOKABEKS and all Covered Parties must unfailingly comply with the following principles:

As active and responsible members of the communities in which we operate, we are committed to respecting all applicable laws wherever we do business, and to following all commonly accepted principles of business ethics, such as transparency, honesty and loyalty.

We refuse to engage in any illegitimate, unfair, or in any way questionable behavior (vis-à-vis the community, public authorities, customers, employees, investors and competitors) to achieve economic targets, which we pursue only through excellent performance, quality, competitive products and services, based on experience, customer care and innovation.
We establish organizational controls designed to prevent Covered Parties from violating these requirements of lawfulness, transparency, honesty and loyalty, and supervise their observance and implementation.
We impose consequences for any violations of these policies and principles.
We maintain accurate books and records, and assure the investors and the community in general total transparency about our activities. · We are committed to fair competition, which benefits us as well as all market operators, customers and shareholders.
We pursue excellence and competitiveness in the market place, offering quality services and products. ·
We safeguard and enhance the value of all our employees.
We respect the environment and try to use natural resources responsibly, with the goal of advancing sustainable development and protecting the rights of future generations.
Article 3 – Shareholders

FOKABEKS is committed to guarantee equal treatment to all classes of shareholders, and to avoid preferential treatment of any class or company. We pursue the reciprocal benefits that derive from belonging to a group of companies while respecting all applicable laws and regulations and the independent interest of each Company as it seeks to create value.

Article 4 – Customers

The excellence of the products and services offered by the FOKABEKS depends on customer care and the readiness to satisfy customer requirements. We therefore seek to assure an immediate, qualified and competent response to customer needs, through honesty, courtesy and cooperation.

Article 5 – Communities

FOKABEKS contributes to the economic welfare and growth of the communities in which it operates by delivering efficient and tech-nologically advanced services. We are a citizen of each locality where we are established to do business, and like individual citizens, we have a responsibility to support the community. It is our goal to take part in projects to further the welfare of our local communities and thus be a good and contributing citizen.

FOKABEKS adheres to all applicable laws and regulations and maintain good relations with local, national and super-national Authorities, based on by full and active cooperation and on transparency. Consistent with these objectives and with the responsibilities they have assumed toward different stakeholders, FOKABEKS recognizes research and innovation as priority conditions for growth and success.

FOKABEKS views favorably and, when necessary, support social, cultural and educational initiatives directed at enhancing the individual and improving his/her living conditions. FOKABEKS does not disburse contributions, advantages or other conveniences or things of value to government officials (including employees of state-owned or controlled entities or enterprises), political parties or trade union organizations, nor to their representatives or candidates, ex-cept as permitted by applicable laws and by the provisions of this Code and other applicable FOKABEKS policies.

Article 6 – Human Resources

FOKABEKS recognizes the central role of human resources; the professional contribution of employees, in a framework of mutual loyalty and trust, is the essential ingredient for success in every business concern. FOKABEKS safeguards safety and health in working environments and consider the respect of worker rights fundamental to the carrying out of business activities. Employment contracts and FOKABEKS policy guarantee equal opportunities and favor the professional growth of each individual.

Article 7 – Environment

FOKABEKS believes in a global sustainable growth in the common interest of all shareholders, present and future. Their investment and business choices are consequently fashioned to respect the environment and public health. Without prejudice to compliance with specified forceable regulations, FOKABEKS takes environmental issues into consideration when defi-ning their choices, also by adopting -if operationally and economically feasible- eco-compatible production technologies and methods, with the objective of reducing the environmental impact of their activities.

Article 8 – Anti-Bribery Policy

Bribery of public officials is prohibited.

No Covered Party may provide, either directly or indirectly, anything of value to any Public Official in order to obtain or retain business or to obtain an improper business advantage.
The term “Public Official” is defined very broadly, and includes an employee of a government owned or controlled entity or a public international organization, any political party, any candidate for public office. Whenever dealing with entities or persons connected with a government entity, FOKABEKS employees shall comply with the principles set forth in this Code which govern our conducts and strictly adhere to the FOKABEKS policies and procedures.
Commercial bribery is prohibited.

No Covered Party may provide, either directly or indirectly, anything of value to any person in order to obtain or retain business, confidential in-formation, or an improper business advantage.
No Covered Party may accept anything of value in exchange for awarding business, providing confidential information, or an improper business advantage.
The Anti-Bribery Policy requires below conditions;

Offering, paying, or accepting gifts, courtesies, entertainment or travel expenses to, from, or on behalf of a Public Official or any supplier, cus-tomer,or competitor; and
Engaging consultants, agents, lobbyists, joint venture partners or other third parties.
Article 9 – Export Controls and Economic Sanctions

It is the policy of the FOKABEKS to comply with all applicable export control laws. All FOKABEKS employees must comply with these laws. Under no circumstances are FOKABEKS employees permitted to make a transfer, export, re-export, sale, or disposal of any product, technical data or service contrary to applicable export control laws.

FOKABEKS will comply with all applicable economic sanctions laws against certain entities and countries, including applicable economic sanctions imposed by the UN, Turkish Republique and other jurisdictions in which the FOKABEKS conducts business.

Article 10- Observance of Code

FOKABEKS and Covered Parties must strictly adhere to this Code, to all applicable laws and regulations, and to all policies and procedures that may promulgate from time to time to implement this Code.

FOKABEKS is committed to implementing and enforcing specific procedures, regulations and instructions to ensure that all Covered Parties adhere to the values and requirements set forth in this Code.

Violations of this Code, any of the implementing policies and procedures , or of any applicable law or regulation will be grounds for serious disciplinary action, including possible termination of employment and/or termination of business relations.

As part of its commitment to ethical and legal behavior, FOKABEKS requires Covered Parties to report any actual or apparent violations of law or this Code or ethical standards so that they can be investigated and dealt with appropriately. This obligation extends to any instance where one suspects, but is uncertain whether, a violation may be occurring. Failure to comply with the duty to come forward is a violation of this Code and can result in serious disciplinary action, including possible termination of employment and/or termination of business relations

FOKABEKS will investigate all reports made and will not tolerate any kind of retaliation for reports or complaints made in good faith.

All persons subject to this Code have a duty not only to report violations but also to cooperate fully in the investigation of any alleged violation. An employee may be subject to disciplinary action, which may include possible termination of employment, for failing to cooperate or deliberately providing false or misleading information during an investigation.